Some countries impose exchange controls to regulate the flow of money. Where a person has income arising in one of these countries, it may be impossible to bring the income into the UK either because it is not permitted by the authorities in that country or because it is difficult to obtain foreign currency there. In these circumstances, tax could become due on income that was not available to pay the tax bill and hardship could result. Special rules in Chapter 4 Part 8 of ITTOIA05 allow an individual or trustee to claim that unremittable income should not be brought into charge when it arises.

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